Privacy Statement
Your privacy is important to us. We are committed to maintaining the confidentiality of the personal information that you submit through our websites, mobile applications or other means. This statement sets out how we, Alliance Pharm Pte Ltd, its holding company, affiliates and their authorised personnel (collectively referred to herein as “Alliance Healthcare Group”, “Alliance”, “us”, “we” or “our”) manage personal data in connection with the Personal Data Protection Act 2012 (“PDPA” or the “Act”).

By interacting, submitting information, enrolling or signing up for any products or services offered by us, directly or indirectly through any third-party organisation or individual, you agree and consent to Alliance Healthcare Group collecting, using, disclosing and sharing your personal data in the manner set forth in this Privacy Statement.

This statement supplements but does not supersede nor replace any other consents you may have previously provided to us or our partners in respect of your personal data, and your consents herein are additional to any rights which any of us may have at law, to collect, use or disclose your personal data.

Alliance may, from time to time, update, amend, supplement, or substitute this Privacy Statement to ensure that it is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Please check back regularly for updated information on how we handle your personal data. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on Alliance’s website or mobile application.

Personal Data
In this Privacy Statement, “personal data” refers to any data, whether accurate or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access, including data in our records as may be updated from time to time.

Example of personal data you may provide to us include your name, NRIC, passport or other identification number, telephone number, mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us or through other forms of interaction with you.

1. Collection
We may collect Personal Data in the following ways:

(a) When you submit any form, including but not limited to application, declaration, proposal or referral forms;

(b) When you respond or take part in our surveys, campaigns and other promotional activities;

(c) When you interact with our staff or business partners, including call centre personnel, client servicing personnel, and other representatives via email, telephone calls (which are recorded), letters, memos, fax, face-to-face-meetings, digital platforms;

(d) When you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us;

(e) When you use our services directly or through our partners, whether through our website or mobile applications;

(e) When you provide your personal data (directly or through your employer or our business partners) to use or access some of our services, whether provided in-person or through our website or mobile application(s);

(h) When we receive references from our business partners and third parties, regardless of the referral came from you;

(i) When you submit an employment application or when you provide documents or information, including your resume and/or Curriculum Vitae in connection with any appointment under us;

(j) When we are performing finance functions, such as preparing for tax filing, processing payments, credit notes and refunds, billing, accounting and auditing, and other related activities for the maintenance of proper book-keeping of our operations;

(k) When your images are captured by us via CCTV cameras while you are within our premises or via photographs or videos taken by us or our designated partners when you attend events hosted by us;

(l) When you submit your personal data to us (directly or indirectly through a third party) for any other reason; and

(m) When you submit personal data relating to a third party (e.g., information of your spouse, or children), for the purpose of us offering our products and/or services to that third party.

By submitting such information to us, you warrant that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

1.1 Types of Personal Data We Collect about you
Depending on the nature of transactions you have with us, the types of personal data we collect about you may include:

(a) Your personal information, such as name and NRIC;

(b) Contact information, such as residential address, email address and mobile phone number;

(c) Your financial information, such as bank account number, credit card details and other related payment details;

(d) Your personal government-issued identification document numbers such as NRIC/FIN/work permit/birth certificate and passport numbers; as required by healthcare sectoral law for purposes of medical treatment or necessary to accurately establish or verify your identity to a high degree of fidelity;

(e) Personal background (such as nationality and race), family background (such as marital status and names of family members), personal profile (such as academic qualification and work experience) and other information necessary for the hiring process or to other special requests.

(g) We may also collect non-personally identifiable information about you, such as use of our website, internet protocol addresses, browser and computer system information, cookies, invisible pixels, web beacons, and aggregated data related to your use of our platforms.

You are assured that we will not collect your personal data more than necessary to fulfil one or more purposes for which the data is collected. Whilst we will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date, you shall ensure that all personal data submitted to us is complete, accurate, true and correct. If there is a change to your contact information, such as your address, email address, or telephone number, do update us to ensure you will continue to receive communications from us without disruption or delay. Failure to do so may result in our inability to provide you with products and/or services that you have requested.

1.2 Obtainment of Consent
We will only collect, use, disclose, process, transfer and retain personal data for the purposes mentioned in Section 2 with your consent or as allowed or required by law. We will notify you of the purposes for which we will collect, use and disclose your personal data before or at the time we collect it.

You can give your consent expressly or impliedly. Your express consent can be given to us in writing, verbally (e.g. through your communication with our personnel) or electronically (e.g. through our website). Your implied consent can be given to us from your action or nature of dealings, for instance, when you or a third party acting on your behalf provide us with your personal data to facilitate the provision of our services to you.

Any party authorised by you (including a person having a power of attorney to act on your behalf) may:
• allow us to collect, use, disclose, transfer and retain personal data for the above purposes; and
• access your personal data or policy information.

If you provide us with the personal data of another person, you represent and warrant to us that you have been appointed and authorized by the other person to act on his behalf. This includes providing consent to our collection, use, disclosure, transfer and retention of his personal information and sensitive personal information.

1.3 Consequences of Not Providing Personal Data or Consent
Failure to provide the requested personal data or to grant consent to this Privacy Statement may result in our inability to offer or perform certain services or obligations. Specifically, if the requisite personal data is not provided, we may be unable to proceed with your recruitment, process applications, conduct medical consultations, manage insurance claims, or undertake other related services as required. Furthermore, in the absence of the necessary consent, we may be legally precluded from collecting, using, or disclosing the personal data for the purposes as outlined in this Privacy Statement. In such instances, Alliance expressly disclaims any liability for any loss, damage, or inconvenience resulting from your failure to provide the necessary personal data or to grant the requisite consent. We shall not be held liable for any inability to provide services, process applications, or fulfil contractual obligations arising out of your refusal or failure to provide the required information or consent. You acknowledge that such failure may impact your ability to receive certain services or benefits and agree that Alliance shall not be liable for any resulting consequences.

1.4 Collection, Use, and Disclosure of Personal Data Under Deemed Consent and Exemptions
We may collect, use, and disclose your personal data based on the concept of “deemed consent” as provided under PDPA. Under certain circumstances, your consent may be deemed to have been given when you voluntarily provide your personal data to us for a specific purpose, even if you do not explicitly express your consent. For example, when you engage in a transaction, request services, or provide personal data to us through our website or mobile applications, it is deemed that you have consented to the collection, use, and disclosure of your personal data for those purposes.

Additionally, we may collect, use, and disclose your personal data without your explicit consent pursuant to the exemptions set out under the PDPA or other applicable laws. These exemptions may include, but are not limited to, the following circumstances:

(a) Legal and Regulatory Requirements: Where required by law or to comply with legal or regulatory obligations, including cooperation with law enforcement agencies, the collection, use, and disclosure of your personal data may occur without your explicit consent.

(b) Performance of Contractual Obligations: When necessary to perform obligations under a contract to which you are a party, or for pre-contractual steps taken at your request, we may collect, use, or disclose your personal data without obtaining explicit consent.

(c) Protection of Vital Interests: In emergency situations, where necessary to protect your vital interests or the vital interests of another individual (e.g., health and safety), your personal data may be collected, used, or disclosed without consent.

(d) Public Interest and Legal Claims: Your personal data may be used or disclosed for purposes related to public interest, legal claims, or the establishment, exercise, or defence of legal rights or claims.

(e) Other Exemptions under the PDPA: We may also rely on other specific exemptions under the PDPA or other applicable laws that permit the collection, use, and disclosure of personal data without your consent.

In such instances, we will take reasonable steps to ensure that the collection, use, and disclosure of personal data complies with the requirements of the PDPA and is necessary for the legitimate purpose for which it is collected.

2. Purpose and Usage of Data
Personal Data may be shared among our subsidiaries, affiliates, partners and third parties to enable us to provide service to you and for our business purposes as allowed under the Act. We may use the personal data for one or more of the following purposes:

2.1 Provision and Improvement of Services
(a) Providing you with our services;

(b) Providing customer service and administrative support such as responding to, processing and handling your enquiries, requests, feedback and complaints, issuing letters of guarantee, administrating insurance coverage and processing claims and settlement of bills and other credit-related activities;

(c) Whenever you opt-in for our marketing information, providing you with information that may be of interest, such as publications, events, news and promotional materials relevant to your business, potential needs and purchases;

(d) Generating reports and performance of analytics for the purposes of developing or improving our products, services, security, service quality and marketing strategies;
(e) Verifying your identity;

(f) Requesting feedback or participation in surveys as well as conducting market research;

(h) Purposes which are related to the aforesaid; and/or

(i) Purposes as permitted under the applicable law.

2.2 Other Business and Legal Purposes
(a) Office management, operations, and administration purposes and for independent and conflict clearance, due diligence and background checks in accordance with legal, regulatory and professional requirements;

(b) Performing human resource management, training, and career development;

(c) Assessing your or your organisation’s suitability as an employee, external services provider, business partner, or vendor for AHG;

(d) Managing and preparing reports on incidents or accidents;

(e) Managing the safety and security of our premises and services including but not limited to carrying out CCTV surveillance and conducting clearances;

(f) Preventing, detecting, and investigating crime, including fraud and money laundering or terrorist financing and analysing and managing commercial risks;

(g) Performing our obligations arising from any contracts entered into between you and us;

(h) Performing our obligations arising from any contracts entered into between us and/ or the relevant third parties;

(i) Complying with legal obligations and regulatory requirements;

(j) generating internal reports for legitimate business interest or improvement;

(k) Protecting and enforcing our contractual or legal rights and obligations;

(l) and/or purposes which are related to the aforesaid.

These purposes may also apply even if you do not maintain an account with us or your account or relationship has been terminated with us. Arrangements are in place to ensure the security of any personal data shared.

3. Disclosure
Subject to the provisions of the applicable law, we may disclose your personal data to parties mentioned below (examples provided are not exhaustive) to the extent necessary to achieve one or more purposes listed in section 2.

Parties to whom disclosure is necessary to provide our services to you, your insurance company or employer (or the employer of the main member):
(a) Entities under Alliance Healthcare Group;
(b) Clinics, hospitals, medical practitioners, and specialists;
(c) Associated medical service providers such as laboratories, imaging and diagnostics services;
(d) Our business partners;
(e) The third parties which are relevant to our dealings;
(f) Banks, payment card processing companies and other financial institutions;
(g) Providers of goods or services such as IT services and courier services

Parties to whom disclosure is necessary for the management, operation and administration of our business: – Providers of professional services such as auditors, lawyers, consultants– Commercial service and training providers.

Parties to whom disclosure is necessary or in our good faith belief that such disclosure is necessary to (i) fulfil our contractual, legal and regulatory obligations, (ii) comply with legal process, (iii) respond to any claim or investigation and protect our rights, property or personal safety:– Government agencies and regulatory authorities such as court, tribunal, Ministry of Health, Ministry of Manpower, IRAS, Police Force– Professional advisor such as lawyers.

We will use our best endeavours to ensure that your personal data is protected by such third parties or cause them to be bound to hold your data in confidence, such as by entering a legally binding instrument with them.

3.1 Oversea Transfers of Personal Data
If there is a need for us to transfer your personal data to an organisation outside of Singapore, whether is within Alliance Healthcare Group or not, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not the case, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.

4. Security
To safeguard your personal information, all electronic storage, hosting, processing, transmission and backup (for the purpose of disaster recover or otherwise) of personal and other information are secured with appropriate administrative, physical and technical security measures.

While we take reasonable efforts to maintain the confidentiality and security of your personal data, we cannot guarantee that any information that is transmitted or stored electronically is completely secure or that no harmful code will enter our website (for example viruses, bugs, trojan horse, spyware, adware).

For users with username and password login, you undertake to keep the username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person and to inform us as soon as reasonably practical if you know or suspect that someone else has access to your username and password or believed that the confidentiality has been compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damage from any security breaches on unauthorised and/or fraudulent use of your username and password.

5. Retention
We will retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required for legal or business purposes. Any personal data which are no longer needed for legal or business purposes will be destroyed or hashed according to our document retention guidelines.

6. Usage of cookies and analytical tools
Our website uses cookies. By using our website, you consent to our use of cookies, which will provide you with a more personalised experience. You can choose to turn off all cookies. If you turn the cookies off, you will not have access to many features that make your user experience more efficient, and some of our services may not function properly. Please refer to your browser’s documentation to check if the cookies have been enabled on your computer or to request not to receive cookies.

We use Google Analytics to analyse the use of our website. Google Analytics generates statistical and other information about our website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of our website. Google will store this information. Besides, Google Analytics is also used for remarketing and behavioural targeting. We advertise on third party websites to you after you have visited our website, we, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our website. If you want to opt out of Google Analytics, you can download and install the add-on for your web browser at https://tools.google.com/dlpage/gaoptout.

We may also include third party links on our website for your convenience and information. These linked sites have separate and independent privacy policies and hence we undertake no responsibility or liability for the content and activities of these link sites and we encourage you to consult the privacy notices of their sites.

7. Review, Correction and Withdrawal
We may, upon written request, allow you to view your stored personal information and how it may have been used and/or disclosed by us in the past one year, subject to legal requirements. We reserve the right to charge a reasonable administrative fee for this service. We will respond to such a request within 30 days of receipt of your written request.

Kindly inform us in writing if any personal information which we hold about you needs to be corrected or updated.

Subject to applicable law, regulations and professional standards at any time, you may give us reasonable written notice of your withdrawal of consent to collect, use or disclose the personal information. If you choose to withdraw your consent to any or all of the disclosure of your personal data, we will not be in a position to continue providing our services to you. Withdrawal may also result in the termination of any agreement you may have with us.

You have a choice to withdraw your consent to receive marketing or promotional materials/communication. You may contact us using the contact details found below. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from us.

8. Enquiries
If you require more information relating to this statement or require amendments or withdraw your consent, please contact us at:

Data Protection Officer
Alliance Healthcare Group
25 Bukit Batok Crescent #07-12, The Elitist
Singapore 658066
Email: [email protected]

If your personal data was provided to us by a third party, kindly contact that organisation or your representative to make such a request or query on your behalf.

Last updated: 19 December 2024